Motion to Strike in Mazie Slater Katz & Freeman, Vs Rudderow Sharo| Trellis.Law

On October 20, 2022 a Order was filed involving a dispute between Mazie Slater Katz &Freeman,L, and -100 John And Jane Does 1, Abc Corps. 1-10, Robert Rudderow, Sharon Rudderow, for Defamation in the District Court of Essex County.

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David A. Mazie | NJ Atty. No. 017941986
MAZIE SLATER KATZ & FREEMAN, LLC
103 Eisenhower Parkway
Roseland, New Jersey 07068
(973) 228-9898
Attorneys for Plaintiff
SUPERIOR COURT OF NEW JERSEY
MAZIE SLATER KATZ & FREEMAN, LAW DIVISION: ESSEX COUNTY
LLC, DOCKET NO.: ESX-L-6226-22

Plaintiff,
CIVIL ACTION
v.
NOTICE OF MOTION FOR RELIEF
SHARON RUDDEROW; ROBERT FOR DEFENDANTS’ FAILURE TO
RUDDEROW; JOHN AND JANE DOES COMPLY WITH COURT ORDER
1-10; AND ABC CORPS. 1-10,

Defendants.

TO: Lawrence H. Kleiner
Lawrence H. Kleiner, LLC
294 Harrington Avenue, Suite 2
Closter, NJ 07624
Attorney for Defendants Sharon and Robert Rudderow

PLEASE TAKE NOTICE that on April 12, 2024, at 9:00 a.m. in the forenoon or

as soon thereafter as counsel may be heard, the undersigned attorneys for Plaintiff, shall

move before the Honorable Roselyn D. Holmes Grant, J.S.C. of the Superior Court of New

Jersey, Essex County Courthouse, Newark, New Jersey for an Order striking and

suppressing Defendants’ Answer and Defenses with prejudice, entering default, and

awarding attorney’s fees and costs to Plaintiff, pursuant to Rule 4:23-2, for failing to comply

with this Court’s April 28, 2023 and March 1, 2024 Orders.

PLEASE TAKE FURTHER NOTICE that the moving party requests oral

argument.

PLEASE TAKE FURTHER NOTICE that a proposed form of Order is attached.
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PLEASE TAKE FURTHER NOTICE that no trial date has been scheduled in this

matter. The current discovery end date is May 22, 2024. 1

MAZIE SLATER KATZ & FREEMAN, LLC
Attorneys for Plaintiff

By: /s/David A. Mazie
DAVID A. MAZIE

Dated: March 18, 2024

1
The current discovery end date is May 22, 2024 pursuant to this Court’s March 1, 2024 Order. (See Trans.
ID No. LCV2024567558) . E-courts, however, still reflects that the discovery end date is February 22, 2024.
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Plaintiff,
CIVIL ACTION
v.
CERTIFICATION OF DAVID A. MAZIE
SHARON RUDDEROW; ROBERT IN SUPPORT OF PLAINTIFF’S
RUDDEROW; JOHN AND JANE DOES MOTION FOR RELIEF FOR
1-10; AND ABC CORPS. 1-10, DEFENDANTS’ FAILURE TO
COMPLY WITH ORDER
Defendants.

DAVID A. MAZIE, of full age, does hereby certify as follows:

1. I am an attorney at law of the State of New Jersey and a partner with the law

firm of Mazie Slater Katz & Freeman, LLC (“Mazie Slater”), attorneys for Plaintiff in this

action. In that capacity, I am fully familiar with the facts set forth herein.

2. I submit this Certification in support of Plaintiff’s motion for relief based on

the Defendants’ continuing failure to comply with the Court’s April 28, 2023 Order

compelling them to produce full and complete discovery responses as well as this Court’s

March 1, 2024 Order requiring Defendants to provide full and complete responses by March

15, 2024. (Attached hereto as Exhibit A is a copy of the April 28, 2023 Order and attached

hereto as Exhibit B is a copy of the March 1, 2024 Order).

3. This is a defamation case involving Mazie Slater’s former clients, Defendants

Sharon and Robert Rudderow. After successfully obtaining a multi-million-dollar

settlement for Defendants, Defendants (and their proxies, assumed to be their family

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members/friends) posted a number of false online reviews regarding Mazie Slater, and

several of its attorneys, falsely stating that their case was settled for little or no money, and

falsely disparaging the legal work performed by Mazie Slater and its attorneys. This was

done with the deliberate intent to harm the reputation and business of Mazie Slater.

4. On October 20, 2022, Plaintiff filed a Complaint in this matter, which

included a demand for documents. (Attached hereto as Exhibit C is a copy of the

Complaint). The Complaint included twenty-one (21) document demands. (Id. at 17-19)

5. Defendants were served and filed an Answer on November 29, 2022. (See

LCV20224082115).

6. On January 3, 2023, Plaintiff served twenty-five interrogatories on

Defendants. (Attached hereto as Exhibit D is a copy of the Interrogatories).

7. On March 10, 2023, Plaintiff served its answers to interrogatories and

responses to document requests propounded by Defendants. (Attached hereto as Exhibit E

is a copy of the March 10, 2023 Letter serving Plaintiff’s discovery responses).

8. Defendants failed to respond to Plaintiff’s demand for documents and

interrogatories, which led to the entry of the April 28. 2023 Order. See Exhibit A. The April

28, 2023 Order required that Defendants “produce full and complete responses to

Plaintiff’s demand for documents and interrogatories within fourteen (14) days of the date

of this Order[.]” (Id.) (emphasis added). This Court noted that discovery was requested in

October 2022. (Id.) Of note, the return date was carried at the request of defense counsel,

who claimed that Defendants needed more time to provide the discovery responses. In

addition, in its opposition to the motion to compel discovery, defense counsel asked the

Court to provide more time to respond to the discovery requests than Plaintiff asked for, and

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the Court accommodated Defendants with an allowance of fourteen days from entry of the

Order to provide the discovery.

9. Defendants failed to provide the ordered discovery, in violation of the April

28, 2023 Order, and Plaintiff filed a motion which resulted in Defendants’ Answer and

defenses to be “stricken without prejudice.” (Attached hereto as Exhibit F is a copy of the

July 7, 2023 Order).

10. Defendants still did not provide discovery responses and, on August 9, 2023,

Plaintiff filed another motion, seeking to strike Defendants’ Answer and defenses with

prejudice.

11. On October 2, 2023, the eve of oral argument, Defendants provided

incomplete and woefully deficient discovery responses. (Attached hereto as Exhibit G is a

copy of Defendants’ answers to interrogatories and document demands).

12. Defendants also filed a motion to reinstate (see LCV20233009308), which

was heard in conjunction with Plaintiff’s motion to strike Defendants’ Answer and defenses

with prejudice.

13. Oral argument was heard on October 3, 2023. As explained at oral argument

on Plaintiff’s motion to strike with prejudice and Defendants’ motion to reinstate – where

defense counsel acknowledged the need to provide more complete discovery – and as set

forth in Plaintiff’s October 12, 2023 letter to defense counsel, Defendants’ responses were

inadequate and, in violation of this Court’s April 28, 2023 Order, were certainly not “full

and complete responses.” (Attached hereto as Exhibit H is a copy of the October 12, 2023

Deficiency Letter).

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14. This Court granted Plaintiff’s motion and Defendants’ Answer and defenses

were stricken and suppressed with prejudice. (Attached hereto as Exhibit I is the October 3,

2023 Order).

15. On November 9, 2023, Defendants filed a motion for reconsideration (see

LCV20233334632), which Plaintiff opposed. (See LCV20233552219).

16. This Court granted Defendants’ motion to reinstate on the basis that

“[d]iscovery [was] provided.” (See Trans ID No. LCV2024139193, January 17, 2024

Order). 1

17. Defendants continued to remain in default of their discovery obligations

pursuant to the April 28, 2023 Order. As a result, Plaintiff filed another motion to strike

Defendants’ Answer and affirmative defenses with prejudice. (See Trans ID No.

LCV2024405462).

18. On March 1, 2024, during oral argument before this Court, defense counsel

again conceded that more specific answers to interrogatories were necessary and that

documents still needed to be produced. Defense counsel agreed that two (2) weeks would

be enough time to provide responses. As such, it was agreed on the record that these

responses would be provided by no later than March 15, 2024.

19. On March 1, 2024, this Court entered an Order “Defendants shall provide

full and complete discovery responses to Plaintiff’s interrogatories and document

demands within fourteen (14) days by March 15, 2024.” (See Exhibit B) (emphasis

added).

1
This Court entered an Order, dated January 29, 2024, granting Defendants’ and motion for reconsideration
on the same basis. (See LCV2024254080).

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20. To date, and even though Defendants have been on notice of the discovery

deficiencies since October 2023, Defendants have not provided “full and complete

responses” to basic discovery requests. Defendants have had over a year-and-a-half to

provide complete discovery responses and have failed to do so, despite multiple Court

Orders, most recently the March 1, 2024 Order entered by this Court. See Exhibit A,

Exhibit B, Exhibit F, and Exhibit I. Defendants have failed to provide responses even

though at oral argument, on two (2) separate occasions, defense counsel admitted on the

record (and before this Court) that responses were due. Enough is enough. Plaintiff has

been substantially prejudiced by Defendants’ repeated failures to abide by multiple Court

Orders in failing to provide complete responses to basic discovery requests, and this unfair

and prejudicial delay that has allowed this case to languish on the docket.

21. Based upon the foregoing, Plaintiff respectfully requests the entry of an

Order: (1) striking and suppressing the Defendants’ answer and affirmative defenses with

prejudice pursuant to Rule 4:23-2(b)(2) to (3); (2) entering default against the Defendants

pursuant to Rule 4:23-2(b)(3); and (3) directing the Defendants to pay the attorney fees and

expenses pursuant to a certification of services to be filed with the Court within three (3)

weeks of the entry of the Order. R. 4:23-2(b)(4).

I hereby certify that the foregoing statements made by me are true. I am aware that

if any of the foregoing statements made by me are willfully false, I am subject to punishment.

/s/David A. Mazie
DAVID A. MAZIE

Dated: March 18, 2024

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Exhibit A
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ID:LCV20231067942
LCV2024702679

FILED
David A. Mazie | NJ Atty. No. 017941986
MAZIE SLATER KATZ & FREEMAN, LLC April 28, 2023
103 Eisenhower Parkway
Roseland, New Jersey 07068 Hon. Jeffrey B. Beacham, J.S.C.
(973) 228-9898
Attorneys for Plaintiff
SUPERIOR COURT OF NEW JERSEY
MAZIE SLATER KATZ & FREEMAN, LAW DIVISION: ESSEX COUNTY
LLC, DOCKET NO.: ESX-L-6226-22

Plaintiff,
CIVIL ACTION
v.
ORDER COMPELLING DISCOVERY
SHARON RUDDEROW; ROBERT
RUDDEROW; JOHN AND JANE DOES GRANTED
1-10; AND ABC CORPS. 1-10,

Defendants.

THIS MATTER having been opened to the Court by David A. Mazie, attorney

for Plaintiff Mazie Slater Katz & Freeman, LLC (“Mazie Slater”), seeking an Order

compelling the Defendants, Sharon Rudderow and Robert Rudderow, to produce discovery

responses; the Court having considered the moving papers and any opposition filed hereto;

and for good cause shown;

28TH day of April 2023;
IT IS on this _____ GRANTED

ORDERED that Defendants, Sharon Rudderow and Robert Rudderow, are hereby

compelled to produce full and complete responses to Plaintiff’s demand for documents and

interrogatories within fourteen (14) days of the date of this Order; and it is further

ORDERED that a copy of this Order shall be served upon all counsel of record

within five (5) days of the date hereof.

THIS DISCOVERY WAS REQUESTED IN OCTOBER 2022.
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________________________________________
HON. JEFFREY B. BEACHAM

X
____ Opposed

____ Unopposed
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Exhibit B
ESX-L-006226-22
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ID:LCV2024559303
LCV2024702679

David A. Mazie | NJ Atty. No. 017941986
MAZIE SLATER KATZ & FREEMAN, LLC
103 Eisenhower Parkway FILED
Roseland, New Jersey 07068 9:28 am, Mar 04, 2024
(973) 228-9898
Attorneys for Plaintiff
SUPERIOR COURT OF NEW JERSEY
MAZIE SLATER KATZ & FREEMAN, LAW DIVISION: ESSEX COUNTY
LLC, DOCKET NO.: ESX-L-6226-22

Plaintiff,
CIVIL ACTION
v.

SHARON RUDDEROW; ROBERT
RUDDEROW; JOHN AND JANE DOES ORDER DISMISSING DEFENDANTS’
1-10; AND ABC CORPS. 1-10, ANSWER AND DEFENSES WITHOUT
PREJUDICE
Defendants.

THIS MATTER having been opened to the Court by David A. Mazie, attorney

for Plaintiff Mazie Slater Katz & Freeman, LLC (“Mazie Slater”), seeking an Order
without prejudice
striking and suppressing Defendants’ Answer and Defenses with prejudice pursuant to Rule

4:23-2(b); and the Court having considered the moving papers and the opposition filed

thereto, and having heard oral argument on March 1, 2024; and for good cause shown;

01 day of March, 2024;
IT IS on this _____

ORDERED:

1. Defendants Sharon and Robert Rudderow’s Answer and Defenses are hereby

stricken and suppressed, without prejudice, for failure to comply with the Court’s Order

directing Defendants to serve full and complete discovery responses, filed April 28, 2023,

pursuant to Rule 4:23-2(b)(3); and

2. Defendants shall provide full and complete discovery responses to Plaintiff’s

interrogatories and document demands within fourteen (14) days by March 15, 2024; and
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3. In the event that Defendants fail to provide full and complete responses within

fourteen (14) days of March 1, 2024, Defendants’ Answer and Defenses shall be stricken

and suppressed with prejudice, and default entered by operation of this Order; and

4. The discovery end date is hereby extended until May 22, 2024; and

FURTHER ORDERED that electronic filing of this Order by the Court shall

constitute service of the Order on the Defendants.
ORDERED that a copy of this order shall be served upon all parties/counsel of Record within
seven (7) days hereof, per the Rules of the Court.
________________________________________
HON. ROSELYN D. HOLMES GRANT, J.S.C.

____ Opposed

____ Unopposed
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Exhibit C
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David A. Mazie | NJ Atty. No. 017941986
MAZIE SLATER KATZ & FREEMAN, LLC
103 Eisenhower Parkway
Roseland, New Jersey 07068
(973) 228-9898
Attorney for Plaintiff

MAZIE SLATER KATZ & FREEMAN, SUPERIOR COURT OF NEW JERSEY
LLC, LAW DIVISION – ESSEX COUNTY
DOCKET NO.: ESX-L-
Plaintiff,

vs. Civil Action
SHARON RUDDEROW; ROBERT
RUDDEROW; JOHN AND JANE DOES
1-100; AND ABC CORPS 1-10,
COMPLAINT AND JURY DEMAND
Defendants.

Plaintiff, Mazie Slater Katz & Freeman, LLC (“Mazie Slater”), by way of Complaint

against the Defendants, say as follows:

THE PARTIES

1. Plaintiff Mazie Slater is a limited-liability corporation and law firm that is

located at 103 Eisenhower Parkway, Suite 207, in Roseland, Essex County, New Jersey.

2. Defendant Sharon Rudderow is an individual residing in the State of New

Jersey with a residence at 2250 Shamrock Lane in Millville, Cumberland County, New

Jersey 08332.

3. Defendant Robert Rudderow is an individual residing in the State of New

Jersey with a residence at 2250 Shamrock Lane in Millville, Cumberland County, New

Jersey 08332.
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4. Defendants John and Jane Does 1-100 and ABC Corporations 1-10 are

fictitious individuals or entities who have not yet been identified who served as co-

conspirators with the named Defendants, and/or acted on their own or in other capacities and

are liable and are also responsible for Mazie Slater’s damages.

VENUE AND JURISDICTION

5. Mazie Slater’s office is located in Roseland, Essex County, New Jersey.

6. Sharon Rudderow and Robert Rudderow are both residents of the State of

New Jersey.

7. Jurisdiction is proper, and venue is properly laid. R. 4:3-2(a)(3).

FACTS COMMON TO ALL COUNTS

8. Adam M. Slater, Mazie Slater, and its attorneys represented Sharon and

Robert Rudderow in a complex product liability case and obtained a substantial settlement

for them in excess of $3 million (the exact amount subject to confidentiality) during

mediation.

9. During the time that Adam M. Slater and Mazie Slater represented

Defendants, Defendants sent numerous threatening, derogatory, and harassing emails.

Defendants’ conduct was so outrageous that, at one point, they even altered the release to

increase the amount of the settlement that they had previously agreed to without notifying

anyone.

10. After receiving their settlement monies, Defendants deliberately and

knowingly filed a series of false online reviews regarding Mazie Slater, Adam M. Slater, and

its attorneys, falsely stating that their case was settled for little or no money, and falsely

disparaging the legal work performed by Adam M. Slater, Mazie Slater and its attorneys –
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and also their character – with the purpose of harming their professional reputations and

causing potential clients to choose different law firms for representation, including but not

limited to, the following posts on Google Reviews and Yelp.

11. On January 10, 2022, user “Rose R.,” who upon information and belief is an

alias or pseudonym used by Defendants and/or their co-conspirators, posted on Mazie

Slater’s Yelp page, which was later updated on May 18, 2022, the following:

These reviews are still available online and can be accessed by anyone with internet access.

12. On June 13, 2022, user “Sierra O.,” who upon information and belief is an

alias or pseudonym used by Defendants and/or their co-conspirators, posted on Mazie

Slater’s Yelp page the following:
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This review is still available online and can be accessed by anyone with internet access.

13. Approximately three months ago, user “A. Magonigal,” who upon

information and belief is an alias or pseudonym used by Defendants and/or their co-

conspirators, posted the following on Mazie Slater’s Google Review page:

This review is still available online and can be accessed by anyone with internet access.

14. Around that time, user “Kmt. L,” who upon information and belief is an alias

or pseudonym used by Defendants and/or their co-conspirators, posted the following on

Plaintiff Mazie Slater’s Google Review page:
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This review, upon information and belief, was taken down by Google on or about October

11, 2022 or October 12, 2022.

15. Around that time, user “T. Tomcat,” who upon information and belief is an

alias or pseudonym for Defendants and/or their co-conspirators, posted the following on

Mazie Slater’s Google Review page:

This review, upon information and belief, was taken down by Google on or about October

11, 2022 or October 12, 2022.

16. In September 2022, user “J. Malloy,” who upon information and belief is an

alias or pseudonym for Defendants and/or their co-conspirators, posted the following on

Mazie Slater’s Google Review page:
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This review, upon information and belief, was taken down by Google on or about October

11, 2022 or October 12, 2022.

17. Given these false and defamatory statements that were posted on the internet,

on October 3, 2022, Mazie Slater emailed Defendants a Demand to Cease and Desist. Mazie

Slater indicated that over the past several months, Defendants have “posted a number of

defamatory online reviews with the express intention to dissuade potential clients from

hiring Mazie Slater.” Mazie Slater informed Defendants that “we are now prepared to take

legal action against you if you do not immediately take down the false reviews and agree in

a written agreement to never publicly defame or disparage Mazie Slater, its attorneys, and

employees ever again.”

18. On October 4, 2022, one day after Defendants received Mazie Slater’s

Demand to Cease and Desist, user “K. Malloy,” who upon information and belief is an alias

or pseudonym used by Defendants and/or their co-conspirators, posted the following on

Mazie Slater’s Google Review page:
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19. This review is no longer available on Google Reviews, but the same user,

who upon information and belief is an alias or pseudonym used by Defendants and/or their

co-conspirators, posted the following on Plaintiff Mazie Slater’s Google Review page:

This review is still available online and can be accessed by anyone with internet access.

20. That same day, user “Joe O’Brien,” who upon information and belief is an

alias or pseudonym used by Defendants and/or their co-conspirators, posted the following

on Mazie Slater’s Google Review page:
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21. This review is no longer available on Google Reviews, but user “R.R.,” which

upon information and belief is the same alias or pseudonym as “Joe O’Brien” as well as an

alias or pseudonym used by Defendant Robert Rudderow and/or his co-conspirators, later

posted the following:

This review, upon information and belief, was taken down by Google on or about October

11, 2022 or October 12, 2022 as it blatantly violated Google’s policies.

22. These posts were available and intended by Defendants to be viewed by

anyone with access to the internet, for the purpose of falsely disparaging and harming Mazie

Slater and its attorneys’ professional reputation, and to damage Mazie Slater’s business. In
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addition, Defendants intended to deprive potential clients of the opportunity to be

represented by Mazie Slater and its attorneys.

23. Google has since escalated the situation and removed four more of the

reviews becausethe posts violated their policies; but, Defendants and/or their co-conspirators

continue to post false, disparaging, and harassing commentary concerning Mazie Slater, its

attorneys, and its business services.

FIRST COUNT
(Defamation)

1. Plaintiff incorporate by reference each preceding paragraph as though fully

set forth at length herein.

2. Defendants and/or their co-conspirators’ posts on Google Reviews and Yelp

contain intentionally defamatory and disparaging statements concerning Adam M. Slater,

Mazie Slater, its attorneys and employees, its business, and its business services. The

defamatory and disparaging statements about Mazie Slater are reckless, outrageous,

unceasing, and verifiably false.

3. Mazie Slater is a law firm that has enjoyed a good name and reputation for

more than fifteen years. Adam M. Slater has practiced law for nearly thirty years and has

established a good name and reputation during his career.

4. The defamatory and disparaging statements by Defendants and/or their co-

conspirators have been written or otherwise published to third persons intentionally,

maliciously, recklessly, in bad faith, and/or negligently.

5. Defendants and/or their co-conspirators’ defamatory and disparaging

statements have been re-published by Defendants, John and Jane Does 1-100, and/or other

third parties through “likes.”
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6. As a direct and proximate cause of Defendants’ defamatory and disparaging

statements, Mazie Slater’s reputation and good will have been substantially and extremely

harmed, and are at risk of further substantial harm by the past, continuing, and ongoing

defamatory and disparaging statements by Defendants that remain published on the internet.

7. Defendants’ and/or their co-conspirators’ defamatory and disparaging

statements have caused substantial economic injury to Mazie Slater.

8. Defendants’ defamatory and disparaging statements are deliberately and

materially misleading and false, and have the further effect of depriving potential clients of

their choice of attorney, in the event that they foreseeably believe and/or rely on Defendants’

false and defamatory statements and exclude Mazie Slater from consideration as their

attorneys.

WHEREFORE, Plaintiff demand judgment against Defendants, jointly and

severally, as follow:

(a) Declaring that Defendants are liable to Plaintiff for defamation;

(b) Enjoining, at first preliminarily to prevent further irreparable injury, and then

permanently, Defendants and compelling them to account for and remove all

such defamatory and disparaging statements and posts on Google Reviews, Yelp,

and any other internet or other publication sources, if any;

permanently, Defendants from using or operating any means of publication

including the internet or a website, to defame and disparage and cause further

irreparable harm to Plaintiff;

(d) Awarding Plaintiff compensatory damages;
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(e) Awarding Plaintiff punitive damages;

(f) Awarding Plaintiff pre-judgment and post-judgment interest;

(g) Awarding attorney’s fees, and costs and expenses of suit;

(h) Awarding such further relief as the Court deems equitable and just.

SECOND COUNT
(Tortious Interference with Prospective Economic Advantage)

1. Plaintiff incorporate by reference each preceding paragraph as though fully

set forth at length herein.

2. Mazie Slater has a protectable interest in their ongoing business and

prospective economic advantage.

3. Defendants, individually and/or collectively, intentionally interfered with

Mazie Slater’s protectable interest in their ongoing business and prospective economic

advantage by posting and publishing false, defamatory, and disparaging statements relating

to their legal services.

4. Defendants were without justification when they willfully, maliciously,

and/or intentionally interfered with Mazie Slater’s protectable interest in its ongoing

business and prospective economic advantage, with a reasonable likelihood that the

interference would cause the loss of prospective gain to Mazie Slater.

5. As a direct and proximate result of Defendants’ conduct and interference,

Mazie Slater has suffered and continue to suffer injury and damages to their reasonable

expectations of prospective economic advantage.

WHEREFORE, Plaintiff demand judgment against Defendants, jointly and

severally, as follows:
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(a) Declaring that Defendants and/or their co-conspirators are liable to Plaintiff for

tortious interference with prospective economic advantage;

(b) Enjoining, at first preliminarily to prevent further irreparable injury, and then

permanently, Defendants and compelling them to account for and remove all

such defamatory and disparaging statements and posts on Google Reviews, Yelp,

and any other internet or other publication sources, if any;

permanently, Defendants from using or operating any means of publication

including the internet or a website, to defame and disparage and cause further

irreparable harm to Plaintiff;

(d) Awarding Plaintiff compensatory damages;

(e) Awarding Plaintiff punitive damages;

(f) Awarding Plaintiff pre-judgment and post-judgment interest;

(g) Awarding attorney’s fees, costs and expenses of suit;

(h) Awarding such further relief as the Court deems equitable and just.

THIRD COUNT
(Civil Conspiracy)

1. Plaintiff incorporate by reference each preceding paragraph as though fully

set forth at length herein.

2. Defendants Sharon and Robert Rudderow are not alone in their fraudulent,

intentional, and unceasing false and defamatory attacks on Mazie Slater, Adam M. Slater,

and its attorneys.

3. The defamatory and disparaging posts relating to Mazie Slater were

orchestrated by unknown co-conspirators, John and Jane Does 1-100.
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4. Defendants Sharon and Robert Rudderow and unidentified John and Jane

Does 1-100 have acted, and are acting, in concert to commit the unlawful and tortious acts

alleged herein, including defamation and tortious interference with prospective economic

advantage, as part of a common scheme designed and intended to harm Mazie Slater.

5. Defendants Sharon and Robert Rudderow and unknown John and Jane Does

1-100 each understood the objectives of the scheme, accepted the objectives of the scheme,

and agreed to do their part to further the scheme.

6. Defendants Sharon and Robert Rudderow and unknown John and Jane Does

1-100 have agreed and acted to tortiously defame and interfere with prospective economic

advantage by publishing numerous defamatory and disparaging statements on the internet,

and potentially by other means of publication.

7. As a direct and proximate result of Defendants Sharon and Robert Rudderow

and John and Jane Does 1-100’s malicious, reckless, and/or negligent acts, including the

false defamatory and disparaging statements on the internet relating to Mazie Slater, its

attorneys, and their character and legal services, Mazie Slater has suffered and continues to

suffer injury and damages.

8. As a direct and proximate result of Defendants’ Sharon and Robert Rudderow

and John and Jane Does 1-100’s malicious, reckless, and/or negligent acts, specifically

posting false defamatory and disparaging statements on the internet, Mazie Slater’s

reputation, good will, and prospective economic advantage have been substantially and

irrevocably harmed.

9. As a direct and proximate result of Defendants’ Sharon and Robert Rudderow

and John and Jane Does 1-100’s malicious, reckless, and/or negligent acts, specifically
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posting false defamatory and disparaging statements on the internet, potential clients of

Mazie Slater have been and will continue to be deprived of the opportunity to retain the

attorney of their choice.

WHEREFORE, Plaintiff demand judgment against Defendants, jointly and

severally, as follows:

(a) Declaring that Defendants are liable to Plaintiff for civil conspiracy;

(b) Enjoining, at first preliminarily to prevent further irreparable injury, and then

permanently, Defendants and compelling them to account for and remove all

such defamatory and disparaging statements and posts on Google Reviews, Yelp,

and any other internet or other publication sources, if any;

permanently, Defendants from using or operating any means of publication

including the internet or a website, to defame and disparage and cause further

irreparable harm to Plaintiff;

(d) Awarding Plaintiff compensatory damages;

(e) Awarding Plaintiff punitive damages;

(f) Awarding Plaintiff pre-judgment and post-judgment interest;

(g) Awarding attorney’s fees, and costs and expenses of suit;

(h) Awarding such further relief as the Court deems equitable and just.
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FOURTH COUNT
(Trade Libel)

1. Plaintiff incorporate by reference each preceding paragraph as though fully

set forth at length herein.

2. Defendants’ statements contain false, defamatory and disparaging

information about Mazie Slater and Adam M. Slater, specifically their character and their

business services.

3. Defendants’ defamatory and disparaging statements about Adam M. Slater,

Mazie Slater, its attorneys, and employees relate to their professional character, standing,

and integrity.

4. The defamatory and disparaging statements about Adam M. Slater, Mazie

Slater, its attorneys and employees, and its business services, are outrageous, unceasing, and

false.

5. The defamatory and disparaging statements by Defendants have been written

or otherwise published to third persons maliciously, willfully, and intentionally.

6. Defendants’ defamatory and disparaging statements have been re-published

by Defendants, John and Jane Does 1-100, and/or other third parties through “likes.”

7. As a direct and proximate cause of Defendants’ defamatory and disparaging

statements, Mazie Slater and its attorneys’ reputations have been substantially and extremely

harmed and are at risk of further substantial harm by the past, continuing, and ongoing

defamatory and disparaging statements by Defendants including those published on the

internet.
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8. Defendants’ libel has caused and continues to cause substantial economic

harm and non-economic harm to Mazie Slater and its attorneys’ good standing and

reputation.

WHEREFORE, Plaintiff demand judgment against Defendants, jointly and

severally, as follows:

(a) Declaring that Defendants are liable to Plaintiff for trade libel;

(b) Enjoining, at first preliminarily to prevent further irreparable injury, and then

permanently, Defendants and compelling them to account for and remove all

such defamato

Case Info

Judge

Joshua D Sanders Track Judge’s New Case

Case No.

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Document Filed Date

March 18, 2024

Case Filing Date

October 20, 2022

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Order: Mazie Slater Katz & Freeman, Vs Rudderow Sharo

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